FL--Parents Planning Programs for the Developmentally Disaled of Florida, Inc.

PROPOSED RULES FOR MEDICAID HOME AND COMMUNITY BASED SERVICES Comments: Parents Planning Programs (PPP), for the Developmentally Disabled of Florida, Inc. The following 10 statements are in response to the request for comments on the proposed rule modification efforts of the Medicaid Home and Community Based Services. Regarding the character of home and community-based settings in which HCBS participants reside and/or receive services, we believe that the rules should provide the following: 1. Person-centered and choice-based settings rather than policy directed Inherent in this principle is avoidance of policies which foster housing discrimination in the "community," e.g., distancing, density and quota requirements for residents of group homes or supported living arrangements. 2. The same residential alternatives that are available to all citizens 3. Expanded private and innovative residential options allowing optimal choice and control 4. Least restricted setting defined by individual needs For individuals who are more dependent on supports and whose cognitive impairments limit their sense of danger, the least restricted setting may be a planned residential community where there is freedom to walk about safely, recreation, opportunity for learning and interaction with peers who share a community of interests, transportation and access to attractions and employment outside the community. 5. Liberty and freedom to live near or next to friends 6. An environment defined by meaningful and enriching supports rather than size An individual living in a "Small, community-based home-like environment" may be lost in a "large" community. A resident of an apartment or housing that is "small" may also be isolated, lonely and neglected. 7. Meaningful alternatives to institutional care: a choice-based, consumer-driven living environment whether a licensed facility, supported living arrangement or privately funded initiative for a planned residential community, if it provides supports, social opportunity and other amenities found in a community for the general population, e.g., a retirement community, co-housing, deed restricted, golf, religious, etc. community 8. Opportunity for community integration – incorporation as equals into society; equal opportunity to live among and share a life style without boundaries Community should be defined by mutually shared interests and relationships, not just where individuals live. 9. Assurance of government neutrality We do not believe that it is the function of a federal or state government or a federally funded organization to make decisions and policies that dictate where and with whom a person may live. 10. Assurance that "Individuals and their families are the primary decision makers regarding the services and supports such individuals and their families receive, including regarding choosing where the individual lives from available options, and play decision making roles in policies and programs that affect the lives of such individuals and their families." (Developmental Disabilities Assistance and Bill of Rights Act, Public Law 106-402)